Thousands of so-called Engle progeny cases present a daunting challenge for tobacco companies.

By establishing that the smoker was addicted, plaintiffs attorneys can benefit from the jury findings in the Engle v. Liggett Group class action lawsuit, even though the Florida Supreme Court later decertified the class.

Dr. Howard Engle was the name plaintiff, a Miami Beach pediatrician and long-term smoker who died of complications from emphysema in 2009. The legacy of the lawsuit includes a Miami jury's determination that tobacco companies placed a dangerous, addictive product on the market and conspired to hide the dangers of smoking for decades.